In 1791, the Bill of Rights written by James Madison were ratified. The first of these rights states that freedom of speech, freedom to petition, freedom to assembly, and freedom of religion are protected. This includes Native Americans and other cultures. Throughout history, there have been many conflicts between religious groups and modernists over land and what the land should be used for. Although the first amendment supplies protection for these tribes and other aspects, much of their sacred land is being jeopardized. When evaluating what should take precedence in land disputes, Religionreligion rules drasticallyare drastic due to the extinct nature of Natives, the history, and the deep connections with sacred land.
To begin with, many Native American tribes are facing major drops in population and have been since the beginning of time. Many factors like disease, violence, displacement, and internal warfare have led to the population decrease
;, as the population decreases the culture and heritage do as well. Because of the limited amount of culture, the population that is still standing should be protected as well as places known to be sacred. If a land dispute breaks out over an area of land known to be sacred, the land should be kept as it is, and the recreational aspect should take place in another location. Correspondingly, many religious groups have disappeared over the course of time, meaning the groups that do still stand today should be able to practice their religion to the full extent in order to prevent them from falling apart. In the Census Releaserelease article, it states “The total population in 2017, according to the Census report estimate, is..."

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